Justia U.S. 1st Circuit Court of Appeals Opinion Summaries

The First Circuit affirmed the dismissal of Petitioner’s petition for habeas corpus relief as time-barred under the one-year statute of limitations set forth in the Antiterrorism and Effective Death Penalty Act (AEDPA), 28 U.S.C. 2244(d)(1), holding that Petitioner was not entitled to relief based on his two tolling theories.As grounds for reconsideration of the dismissal of his habeas petition, Petitioner argued (1) the statute of limitations should be statutorily tolled during the pendency of his motion to stay the execution of his sentence because that motion constituted an application for collateral review under section 2244(d)(2); and (2) the circumstances surrounding his conviction justified equitable tolling of the time between the finality of his Massachusetts convictions and the filing of his habeas petition. The First Circuit disagreed, holding (1) Petitioner’s motion to stay the execution of his sentence was not a request for collateral review and therefore did not toll the one-year statute of limitations; and (2) there was no reason to disrupt the district court’s discretionary ruling on equitable tolling. View "Blue v. Medeiros" on Justia Law

The First Circuit affirmed Defendant’s conviction and sentence without prejudice to his right to raise his claim of ineffective assistance of counsel in a collateral proceeding brought pursuant to 28 U.S.C. 2255, holding that Defendant’s ineffective assistance of counsel claim ought not to be aired for the first time on direct appeal.Defendant pleaded guilty to violating the Mann Act, 18 U.S.C. 2423(a) and was sentenced to a 327-month term of immurement. On appeal, Defendant argued for the first time that he received ineffective assistance of counsel. The First Circuit affirmed, holding that this case did not qualify for an exception to the general rule that an ineffective assistance of counsel claim must first be raised in the district court. View "United States v. Miller" on Justia Law

The Supreme Court affirmed Defendant’s 109-month sentence for possession of child pornography, holding that the government did not violate the plea agreement in this case and that the district court did not err in applying an enhancement for knowingly distributing child pornography.Defendant entered a guilty plea to the charge of possession of child pornography. The district court sentenced Defendant to a 109-month term of immurement. On appeal, Defendant argued that the government breached the terms of the plea agreement by failing to advocate for the bargained-for sentence and that the district court’s finding that he knowingly distributed child pornography was in error. The First Circuit affirmed, holding (1) the district court did not err when it included a two-level enhancement for knowing distribution in its calculation of the guideline sentencing range; and (2) there was no breach of the plea agreement. View "United States v. Montanez-Quinones" on Justia Law

The First Circuit affirmed the district court’s dismissal of Appellant’s federal petition for writ of habeas corpus filed pursuant to 28 U.S.C. 2254, holding that the district court did not err in dismissing the petition.In his petition, Appellant challenged his convictions under Massachusetts law for murder and other offenses, arguing that he received ineffective assistance of counsel, in violation of the Sixth Amendment to the United States Constitution. The district court denied relief. Because Appellant’s case was adjudicated on the merits in state court, the Antiterrorism and Effective Death Penalty Act’s (AEDPA) highly deferential standard of review applied. See 28 U.S.C. 2254(d). The First Circuit affirmed the district court’s denial of habeas relief, holding that any error on the part of counsel was not unsustainable under AEDPA’s deferential review standard. View "Walker v. Medeiros" on Justia Law

The First Circuit affirmed Defendant’s convictions and sentence for conspiring to defraud the United States and stealing government property in violation of 18 U.S.C. 371, 641, holding that there was sufficient evidence to support Defendant’s convictions and that the sentence was procedurally reasonable.Specifically, the First Circuit held (1) there was ample evidence from which a jury could have reasonably determined that Defendant was a knowing and willing participant in a fraudulent scheme of claiming eligibility for Social Security benefits and receiving nearly $100,000 in disability insurance disbursements to which he was not entitled; and (2) the district court’s imposition of Defendant’s sentence was procedurally sound. View "United States v. Sostre-Cintron" on Justia Law

In this 42 U.S.C. 1983 case, the First Circuit affirmed the judgment of the district court granting summary judgment in favor of Kathy Bergeron, a corrections officer, holding that no reasonable juror could conclude that Bergeron was deliberately indifferent to the health and safety of Plaintiff, an inmate, under the Eighth Amendment based on the facts presented by Plaintiff.Plaintiff was severely beaten by other inmates in a cell at a medium-security prison. In his complaint, Plaintiff alleged that Bergeron was deliberately indifferent while doing a round, leading to a delay in his being provided with medical treatment, which exacerbated his injuries. The district court granted summary judgment for Bergeron. The First Circuit affirmed, holding that Plaintiff failed to produce enough evidence for a jury to conclude that Bergeron had the requisite culpable state of mind of deliberate indifference to Plaintiff’s need for medical care. View "Leite v. Goulet" on Justia Law

The First Circuit affirmed Defendant’s sentence for distribution of heroin and fentanyl, holding that the sentence was not substantively unreasonable.After a hearing, the district court sentenced Defendant to 168 months in prison, a sentence that fell within the range stipulated in the plea agreement, as well as between defense counsel’s recommendation and the government’s recommendation. On appeal, Defendant argued that while the sentence was within the range stipulated in the plea agreement, the court should have sentenced him to the stipulated range’s lower bound. Noting that Defendant’s arguments were largely a disagreement with the weight the district court assigned particular factors, the First Circuit affirmed, holding that the factors amply justified the sentence imposed. View "United States v. Gilley" on Justia Law

The First Circuit affirmed the judgment of the district court entering judgment against Plaintiff on his lawsuit against the United States under the Federal Tort Claims Act, 28 U.S.C. 1346(b), 2671-2680, holding that the district court did not err in dismissing Plaintiff’s claim on the clearly-established step of qualified immunity analysis.In his lawsuit, Plaintiff sought to recover damages for injuries he suffered when a Department of Homeland Security agent shot him during the execution of a search warrant at his residence. The district court ruled for the United States, concluding that the United States could not be held liable unless the unlawfulness of the officers’ conduct was clearly established at the time they acted and that, at the time the officers acted, no precedent clearly established that the officers’ conduct was unlawful. The First Circuit affirmed, holding that the officers’ actions did not violate clearly established statutory or constitutional rights of which a reasonable person would have known. View "Escalera-Salgado v. United States" on Justia Law

The First Circuit affirmed Defendant’s conviction of being a felon in possession of a firearm an ammunition and sentence to time served plus three weeks of imprisonment and three years of supervised release, holding that any error was harmless.Specifically, the Court found (1) the district court did not err in denying Defendant’s motion to suppress evidence of the firearm; (2) the district court did not err in granting the government’s motion in limine to preclude Defendant from asserting a necessity defense; and (3) the district court committed a significant procedural error in calculating Defendant’s Guidelines sentencing range, but the error was harmless. View "United States v. Henderson" on Justia Law

The First Circuit affirmed Defendant’s sentence of thirty months’ imprisonment for knowingly failing to update his registration, holding that the district court neither committed clear error in finding that Defendant perjured himself at trial or in imposing a two-level enhancement for obstruction of justice.Defendant, a registered sex offender, was convicted of knowingly failing to update his registration, in violation of 18 U.S.C. 2250(a). Finding that Defendant had committed perjury when he testified at trial in his own defense, the district court imposed a two-level obstruction of justice enhancement. The court then sentenced Defendant at the middle of his Guidelines sentencing range. The First Circuit affirmed, holding that the district court did not err in applying the sentencing enhancement for obstruction of justice because the record provided clear support for the finding that Defendant committed perjury. View "United States v. Nagell" on Justia Law